Plaintiffs do not request that this Court create a new right, but instead that it fulfill its mandate to enforce existing rights to equality and liberty guaranteed by the New Jersey Constitution’s Article I, paragraph 1.

The brief explains that the constitutional principle of religious freedom supports the right of same-sex couples to marry. Because there are no legitimate secular reasons for the State to deny gay couples the profound, state-sanctioned rituals of marriage, the State’s licensing of heterosexual unions only offends the core mandate of religious neutrality.